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HERITAGE HYPOCRISY I

It's no secret that the Heritage Foundation is conservative, but there's a significant distinction between advocating an ideology and actively assisting a candidate for political office. Doing the former is common among tax-exempt nonprofit groups like Heritage and its liberal counterparts; doing the latter is illegal.

Heritage's support of Bob Dole's presidential campaign dangles right on the edge of illegality. In exchange for Dole's signature on a fundraising letter, Heritage gave the candidate one-time use of its mailing list for his own fundraising purposes.

The Internal Revenue Service prohibits tax-exempt organizations from attempting to influence the outcome of an election. Giving something of value, like a mailing list, to a political candidate would certainly violate this regulation. John von Kannon, a Heritage spokesman, argues that it was a fair trade, and thereby legitimate. "We have determined that the value of his signature is equal to the value of the list," he says. Heritage's list rents on the open market for $26,643.33. It would be an astonishing coincidence if Dole's signature is worth precisely that amount.

As a nonprofit, Heritage also cannot endorse a candidate. Dole is of course free to endorse whomever he chooses, but the letter, envelope, and enclosed "Reform Facts" brochure (see opposite page) suggest more than one-way support. Dole's name appears above Heritage's on the envelope and at the top of Heritage's stationery.

The letter reads like a Dole for President ad, mentioning Heritage only incidentally. Dole requests that the reader fill out a survey (with questions like "Which Cabinet Departments would you reduce or cut entirely?") and mail it, along with a donation, to him at the Heritage Foundation--it's not all that clear for whom the donation is intended. Heritage's implied endorsement of Dole couldn't be much stronger.

While Heritage is subject to IRS regulations, Dole has to worry about Federal Election Commission laws. A spokesman for the FEC said that Dole and Heritage would have to definitively prove that the signature's value is equal to or greater than the value of the list. If it weren't, then Heritage would be giving Dole an in-kind donation. Since corporations cannot give anything of value to candidates (and the candidate cannot accept it), both Heritage and Dole would be in trouble with the FEC.

Even if the IRS and FEC determine that the signature-for-list trade does not violate these laws, there's still the matter of how much Dole can spend on his own campaign--since he received federal matching funds, he is limited to $50,000 of his own money. According to both Heritage and Dole, the list was fair compensation for the signature, so Dole essentially put the payment towards his campaign. If he doesn't declare it as a personal contribution and spends more than the limit in other funds, he would be in violation of yet another FEC regulation.

Evidently, Dole's tough-on-crime stance doesn't extend to nonprofits who flout the IRS, or to campaigns that find loopholes in FEC laws.

HERITAGE HYPOCRISY II

In the letter discussed above, Dole takes a second out of his campaign pitch to mention that: "The Heritage Foundation actually lives by the free market system they advocate. Heritage accepts no government funds and relies on voluntary gifts to support their work."

As we pointed out above, Heritage is tax-exempt, one of the biggest forms of government subsidy available.

HERITAGE HIGH-BALLING

In its ongoing efforts to turn Americans against social programs like Medicare, the Heritage Foundation has resorted to phony arithmetic. …